Transfer pricing

Transfer pricing for cross-border transactions can play a major role for multinational group's overall taxation. The transfer pricing rules for documentation of intra-group transactions are extensive and demanding, and effective preparation of transfer pricing documentation is important. Based on BEPS (Base Erosion and Profit Shifting), OECD has updated the guidelines for transfer pricing. As a result, firmer requirements have been implemented for multinational companies.

Taxpayers should expect that their cross border international transactions will face intense scrutiny both domestically and internationally from fiscal authorities. At RSM we have an integrated national and international network of transfer pricing specialists who can assist taxpayers in meeting their specific and unique transfer pricing requirements. Our expertise covers both industry specific and transaction based transfer pricing issues.

Typical questions and services within transfer pricing:

• Analyze tax risk in transfer pricing issues
• Plan and design transfer pricing policy
• Prepare agreements for intra-group transactions
• Prepare transfer pricing documentation
• MAP/APA procedures in accordance with tax treaties

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